ARIZONA BORDER 

SURVEILLANCE 

TECHNOLOGY PLAN

Additional Actions Needed 

to Strengthen Management 

and Assess Effectiveness

Statement of Rebecca Gambler, Director, Homeland 

Security and Justice

Testimony 

Before the Subcommittee on Border 

and Maritime Security, Committee on 

Homeland Security, House of 

Representatives

For Release on Delivery 

Expected at 10:00 a.m. EST

Wednesday, March 12, 2014

GAO-14-411T

United States Government Accountability Office
 

Page 1 GAO-14-411T 

Chairwoman Miller, Ranking Member Jackson Lee, and Members of the 

Subcommittee:

I am pleased to be here today to discuss the findings from our March 

2014 report, being released today, in which we assessed the Department 

of Homeland Security’s (DHS) U.S. Customs and Border Protection’s 

(CBP) efforts to develop and implement the Arizona Border Surveillance 

Technology Plan (the Plan).

1 In recent years, nearly half of all annual 

apprehensions of illegal entrants along the southwest border with Mexico 

have occurred along the Arizona border, according to DHS data. A top 

priority for CBP is preventing, detecting, and apprehending illegal 

entrants. In November 2005, DHS announced the launch of the Secure 

Border Initiative (SBI), a multiyear, multibillion-dollar program aimed at 

securing U.S. borders and reducing illegal immigration. CBP intended for 

the SBI Network (SBInet) to include technologies such as fixed sensor 

towers, a common operating picture, and tactical infrastructure to create a 

“virtual fence” along the southwest border to enhance CBP’s capability to 

detect, identify, classify, track, and respond to illegal breaches at and 

between land ports of entry.2 At a cost of about $1 billion, in 2010, CBP 

deployed SBInet systems, referred to as Block 1 systems, along the 53 

miles of Arizona’s 387-mile border with Mexico that represent one of the 

highest-risk areas for illegal entry attempts. However, in January 2011, in 

response to internal and external assessments that identified concerns 

regarding the performance, cost, and schedule for implementing the 

systems, the Secretary of Homeland Security announced the cancellation 

of further procurements of SBInet systems.3

 

1

GAO, Arizona Border Surveillance Technology Plan: Additional Actions Needed to 

Strengthen Management and Assess Effectiveness, GAO-14-368 (Washington, D.C.: Mar. 

3, 2014). 

2

 The SBInet fixed sensor towers were intended to transmit radar and camera information 

into a common operating picture at workstations manned at all times by U.S. Border Patrol 

agents. The SBInet Common Operating Picture was intended to provide uniform data 

through a command center environment to Border Patrol agents in the field and all DHS 

agencies, and to be interoperable with the equipment of DHS external stakeholders, such 

as local law enforcement. Tactical infrastructure includes pedestrian and vehicle fences, 

roads, and lighting. Ports of entry are officially designated places that provide for the 

arrival at, or departure from, the United States.

3

See, for example, GAO, Secure Border Initiative: DHS Needs to Reconsider Its Proposed 

Investment in Key Technology Program, GAO-10-340 (Washington, D.C.: May 5, 2010), 

and Secure Border Initiative: DHS Needs to Address Significant Risks in Delivering Key 

Technology Investment, GAO-08-1086 (Washington, D.C.: Sept. 22, 2008).
 

Page 2 GAO-14-411T 

After the cancellation of SBInet in January 2011, CBP developed the 

Plan, which includes a mix of radars, sensors, and cameras to help 

provide security for the remainder of the Arizona border. Under the Plan, 

CBP identified seven programs to be implemented ranging in estimated 

costs from $3 million to about $961 million. The three highest-cost 

programs under the Plan are the Integrated Fixed Tower (IFT), Remote 

Video Surveillance System (RVSS), and Mobile Surveillance Capability 

(MSC), accounting for 97 percent of the Plan’s estimated cost.4 In 

November 2011, we reported on CBP’s development of, and estimated 

life-cycle costs for, implementing the Plan.5 Specifically, we reported that 

CBP needed more information for the Plan and its costs before 

proceeding with implementation, and we recommended that CBP, among 

other things, determine the mission benefits to be derived from the 

implementation of the Plan and develop and apply key attributes for 

metrics to assess program implementation, conduct a post 

implementation review and operational assessment of SBInet, and update 

the cost estimate for the Plan using best practices.6

My testimony today is based on and summarizes the key findings of our 

report on the status of the Plan, which was publicly released today.

DHS concurred with 

these recommendations and has actions under way to address some of 

them.

7

 

4

The IFT consists of towers with, among other things, ground surveillance radars and 

surveillance cameras mounted on fixed (that is, stationary) towers. The RVSS includes 

multiple color and infrared cameras mounted on monopoles, lattice towers, and buildings 

and differs from the IFT, among other things, in that the RVSS does not include radars. 

The MSC is a stand-alone, truck-mounted suite of radar and cameras that provides a 

display within the cab of the truck.

Like 

the report, my statement will address CBP’s efforts to (1) develop 

schedules and Life-cycle Cost Estimates for the Plan in accordance with 

5

GAO, Arizona Border Surveillance Technology: More Information on Plans and Costs Is 

Needed before Proceeding, GAO-12-22 (Washington, D.C.: Nov. 4, 2011). A Life-cycle 

Cost Estimate provides an exhaustive and structured accounting of all resources and 

associated cost elements required to develop, produce, deploy, and sustain a particular 

program.

6

Measures and key attributes are generally defined as part of the business case in order 

to explain how they contribute to the mission’s benefits. See Office of Management and 

Budget, OMB Circular No. A-11, Part 7, Section 300, Planning, Budgeting, Acquisition, 

and Management of Capital Assets (Washington, D.C.: Executive Office of the President, 

July 2010). 

7 GAO-14-368. 
 

Page 3 GAO-14-411T 

best practices, (2) follow key aspects of DHS’s acquisition management 

framework in managing the Plan’s three highest-cost programs, and (3) 

assess the performance of technologies deployed under SBInet and 

identify mission benefits and develop performance metrics for 

surveillance technologies to be deployed under the Plan. To conduct work

for the March 2014 report, we analyzed DHS and CBP program 

schedules and Life-cycle Cost Estimates and interviewed DHS and CBP 

officials responsible for developing and overseeing schedules and cost 

estimates, including officials from CBP’s Office of Technology Innovation 

and Acquisition (OTIA), which manages implementation of the Plan. We 

also analyzed DHS and CBP documents, including DHS Acquisition 

Management Directive 102-01 and its associated DHS Instruction Manual 

102-01-001, program briefing slides, budget documents, Acquisition 

Decision Memorandums, and program risk sheets.8 Finally, we analyzed 

performance assessment documentation and metrics used by CBP to 

determine the effectiveness of technologies deployed under SBInet and 

interviewed CBP officials responsible for performance measurement 

activities, and analyzed CBP data on apprehensions, seizures, and asset 

assists from fiscal year 2010 through June 2013 to determine the extent 

to which the data could be used to measure the contributions of SBInet

technologies in enhancing border security.9

 

8

DHS Acquisition Management Directive 102-01, Jan. 20, 2010, and DHS Instruction 

Manual 102-01-001, Acquisition Management/Instruction Guidebook, Oct. 1, 2011.

We conducted this work in 

accordance with generally accepted government auditing standards. 

More detailed information on the scope and methodology of our published 

report can be found therein.

9

 An asset assist is what happens when a technological asset, such as a SBInet

surveillance tower, or a non-technological asset, such as a canine team, contributes to 

apprehensions or seizures. In our March 2014 report, apprehensions data included 

individuals arrested and identified as deportable aliens, consistent with Border Patrol’s 

definition. 
 

Page 4 GAO-14-411T 

In our March 2014 report, we assessed OTIA’s schedules as of March 

2013 for the IFT, RVSS, and MSC programs and found that these 

program schedules addressed some, but not all, best practices for 

scheduling. The Schedule Assessment Guide identifies 10 best practices 

associated with effective scheduling, which are summarized into four 

characteristics of a reliable schedule—comprehensive, well constructed, 

credible, and controlled.10 According to our overall analysis, OTIA at least 

partially met the four characteristics of reliable schedules for the IFT and 

RVSS schedules (i.e., satisfied about half of the criterion), and partially or 

minimally met the four characteristics for the MSC schedule, as shown in 

table 1. For example, we reported that the schedule for the IFT program 

partially met the characteristic of being credible in that CBP had 

performed a schedule risk analysis for the program, but the risk analysis 

was not based on any connection between risks and specific activities. 

 

10 GAO, GAO Schedule Assessment Guide: Best Practices for Program Schedules,

GAO-12-120G (exposure draft) (Washington, D.C.: May 2012). We developed this guide 

through a compilation of best practices that federal cost-estimating organizations and 

industry use. According to this guide, for a schedule to be comprehensive, among other 

things, the schedule should (1) capture all activities, as defined in the work breakdown 

structure, (2) reflect what resources are needed to do the work, and (3) establish the 

duration of all activities and have specific start and end dates. To be well-constructed, 

among other things, all schedule activities are sequenced in the order that they are to be 

implemented with the most straightforward logic possible. To be credible, the schedule 

should reflect the order of events necessary to achieve aggregated products or outcomes, 

and activities in varying levels of the schedule map to one another. Moreover, a schedule 

risk analysis should be conducted to predict a level of confidence in meeting the 

program’s completion date. For a schedule to be controlled, the schedule should be 

updated periodically using actual progress and logic to realistically forecast dates for 

program activities, and a baseline schedule should be maintained to measure, monitor, 

and report the program’s progress.

CBP’s Program 

Schedules and Lifecycle Cost Estimates 

Reflect Some but Not 

All Best Practices
 

Page 5 GAO-14-411T 

Table 1: Summary of Our Schedule Assessments for the Three Highest-Cost Programs under the Arizona Border Surveillance 

Technology Plan

Schedule characteristic 

Integrated

Fixed Towers 

Remote Video

Surveillance Systems

Mobile

Surveillance Capability

Comprehensive Partially met Partially met Partially met 

Well constructed Substantially met Partially met Partially met 

Credible Partially met Partially met Minimally met 

Controlled Partially met Partially met Minimally met 

Source: GAO analysis of Customs and Border Protection data.

Note: Not met—CBP provided no evidence that satisfies any of the criterion. Minimally met—CBP 

provided evidence that satisfies a small portion of the criterion. Partially met—CBP provided evidence 

that satisfies about half of the criterion. Substantially met—CBP provided evidence that satisfies a 

large portion of the criterion. Met—CBP provided complete evidence that satisfies the entire criterion. 

We recommended that CBP ensure that scheduling best practices are 

applied to the IFT, RVSS, and MSC schedules. DHS concurred with the 

recommendation and stated that OTIA plans to ensure that scheduling 

best practices are applied as far as practical when updating the three 

programs’ schedules. 

Further, in March 2014 we reported that CBP has not developed an 

Integrated Master Schedule for the Plan in accordance with best 

practices. Rather, OTIA has used the separate schedules for each 

individual program (or “project”) to manage implementation of the Plan. 

OTIA officials stated that an Integrated Master Schedule for the 

overarching Plan is not needed because the Plan contains individual 

acquisition programs as opposed to a plan consisting of seven integrated 

programs. However, collectively these programs are intended to provide 

CBP with a combination of surveillance capabilities to be used along the 

Arizona border with Mexico. Moreover, while the programs themselves 

may be independent of one another, the Plan’s resources are being 

shared among the programs. 

OTIA officials stated that when schedules were developed for the Plan’s 

programs, they assumed that personnel would be dedicated to work on 

individual programs and not be shared between programs. However, as 

OTIA has initiated and continued work on the Plan’s programs, it has 

shared resources such as personnel among the programs, contributing, in 

part, to delays experienced by the programs. According to schedule best 

practices, an Integrated Master Schedule that allows managers to monitor 

all work activities, how long the activities will take, and how the activities 

are related to one another is a critical management tool for complex 
 

Page 6 GAO-14-411T 

systems that involve the incorporation of a number of different projects, 

such as the Plan.11

DHS did not concur with this recommendation. In particular, DHS stated 

that maintaining an Integrated Master Schedule for the Plan undermines 

the DHS-approved implementation strategy for the individual programs 

making up the Plan and that a key element of the Plan has been the 

disaggregation of technology procurements. However, we continue to 

believe that developing an Integrated Master Schedule for the Plan is 

needed. As we reported in March 2014, this recommendation is not 

intended to imply that DHS needs to re-aggregate the Plan’s seven 

programs into a “system of systems” or change its procurement strategy 

in any form. The intent of the recommendation is for DHS to insert the 

individual schedules for each of the Plan’s programs into a single 

electronic Integrated Master Schedule file in order to identify any resource 

allocation issues among the programs’ schedules. Developing and 

maintaining an Integrated Master Schedule for the Plan could allow OTIA 

insight into current or programmed allocation of resources for all 

programs as opposed to attempting to resolve any resource constraints 

for each program individually.

Thus, we recommended that CBP develop an 

Integrated Master Schedule for the Plan.

In addition in March 2014, we reported that OTIA’s rough order of 

magnitude estimate for the Plan and individual Life-cycle Cost Estimates 

for the IFT and RVSS programs met some but not all best practices for 

such estimates. Cost-estimating best practices are summarized into four 

characteristics—well documented, comprehensive, accurate, and 

credible.12

 

11

Our analysis of CBP’s estimate for the Plan and estimates 

completed at the time of our review for the IFT and RVSS programs 

showed that these estimates at least partially met three of these 

characteristics—well documented, comprehensive, and accurate. In 

terms of being credible, these estimates had not been verified with 

independent cost estimates in accordance with best practices. We 

recommended that CBP verify the Life-cycle Cost Estimates for the IFT 

GAO-12-120G. 

12 GAO, GAO Cost Estimating and Assessment Guide: Best Practices for Developing and 

Managing Capital Program Costs, GAO-09-3SP (Washington, D.C.: March 2009). The 

methodology outlined in the Cost Estimating and Assessment Guide is a compilation of 

best practices that federal cost-estimating organizations and industry use to develop and 

maintain reliable cost estimates throughout the life of an acquisition program.
 

Page 7 GAO-14-411T 

and RVSS programs with independent cost estimates and reconcile any 

differences. 

DHS said it concurred with this recommendation, although we reported

that DHS’s planned actions will not fully address the intent of the 

recommendation unless assumptions underlying the cost estimates 

change. In particular, DHS stated that at this point it does not believe that 

there would be a benefit in expending funds to obtain independent cost 

estimates and that if the costs realized to date continue to hold, there may 

be no requirement or value added in conducting full-blown updates with 

independent cost estimates. DHS noted, though, that if this assumption 

changes, OTIA will complete updates and consider preparing 

independent cost estimates, as appropriate. We recognize the need to 

balance the cost and time to verify the Life-cycle Cost Estimates with the 

benefits to be gained from verification with independent cost estimates. 

However, we continue to believe that independently verifying the Lifecycle Cost Estimates for the IFT and RVSS programs and reconciling any 

differences, consistent with best practices, could help CBP better ensure 

the reliability of the estimates.

In March 2014, we reported for the Plan’s three highest-cost programs—

IFT, RVSS, and MSC—DHS and CBP did not consistently approve key 

acquisition documents before or at the Acquisition Decision Events, in 

accordance with DHS’s acquisition guidance. An important aspect of an 

Acquisition Decision Event is the review and approval of key acquisition 

documents critical to establishing the need for a program, its operational 

requirements, an acquisition baseline, and test and support plans, 

according to DHS guidance. On the basis of our analysis for IFT, RVSS, 

and MSC programs under the Plan, we reported that the DHS Acquisition 

Decision Authority approved the IFT program and the CBP Acquisition 

Decision Authority approved the RVSS and MSC programs to proceed to 

subsequent phases in the Acquisition Life-cycle Framework without 

approving all six required acquisition documents for each program. 

Furthermore, we reported that one document for the IFT program, five 

documents for the RVSS program, and two documents for the MSC 

program were subsequently approved after the programs received 

authority to proceed to the next phase. DHS plans to complete and 

approve those documents for the IFT, RVSS, and MSC programs that 

have not yet been completed and approved.

With regard to one of the required documents—the Test and Evaluation 

Master Plan—we reported in March 2014 that this document for the IFT 

CBP Did Not Fully 

Complete Documents 

for Acquisition 

Decisions Consistent 

with the Guidance
 

Page 8 GAO-14-411T 

program, which was approved by DHS in November 2013, does not 

describe testing to evaluate the operational effectiveness and suitability of 

the system. Rather, the Test and Evaluation Master Plan describes CBP’s 

plans to conduct a limited user test of the IFT. According to the Test and 

Evaluation Master Plan, the limited user test will be designed to 

determine the IFT’s mission contribution. According to OTIA and the Test 

and Evaluation Master Plan, this testing is planned to occur during 30 

days in environmental conditions present at one site—the Nogales 

station. CBP plans to conduct limited user testing for the IFT under the 

same process that is typically performed in any operational test and 

evaluation, according to the Test and Evaluation Master Plan. The 

November 2013 IFT Test and Evaluation Master Plan notes that, because 

the IFT acquisition strategy is to acquire non-developmental IFT systems 

from the marketplace (sometimes referred to as a commercial off-theshelf system), a limited user test will provide Border Patrol with the 

information it needs to determine the mission contributions from the IFTs, 

and thus CBP does not plan to conduct more robust testing. However, 

this approach is not consistent with DHS’s acquisition guidance, which 

states that even for commercial off-the-shelf systems, operational test 

and evaluation should occur in the environmental conditions in which a 

system will be used before a full production decision for the system is 

made and the system is subsequently deployed.

As we reported, we recognize the need to balance the cost and time to 

conduct testing to determine the IFT’s operational effectiveness and 

suitability with the benefits to be gained from such testing. Although the 

limited user test should help provide CBP with information on the IFTs’ 

mission contribution and how Border Patrol can use the system in its 

operations, the limited user test does not position CBP to obtain 

information on how the IFTs may perform under the various 

environmental conditions the system could face once deployed. 

Conducting limited user testing in one area in Arizona—the Nogales 

station—for 30 days could limit the information available to CBP on how 

the IFT may perform in other conditions and locations along the Arizona 

border with Mexico. As of November 2013, CBP intended to deploy IFTs 

to 50 locations in southern Arizona, which can include differences in

terrain and climate throughout the year. 

We recommended that CBP revise the IFT Test and Evaluation Master 

Plan to more fully test the IFT program, before beginning full production, 

in the various environmental conditions in which IFTs will be used to 

determine operational effectiveness and suitability. DHS did not concur 

with this recommendation and stated that the Test and Evaluation Master 
 

Page 9 GAO-14-411T 

Plan includes tailored testing and user assessments that will provide 

much, if not all, of the insight contemplated by the intent of the 

recommendation. However, as we reported in March 2014, we continue 

to believe that revising the Test and Evaluation Master Plan to include 

more robust testing to determine operational effectiveness and suitability 

could better position CBP to evaluate IFT capabilities before moving to 

full production for the system, help provide CBP with information on the 

extent to which the towers satisfy Border Patrol’s user requirements, and 

help reduce potential program risks.

We reported in March 2014 that CBP has identified the mission benefits 

of its surveillance technologies, but does not capture complete data on 

the contributions of these technologies, which in combination with other 

relevant performance metrics or indicators, could be used to better 

determine the contributions of CBP’s surveillance technologies and inform 

resource allocation decisions. CBP has identified mission benefits of 

surveillance technologies to be deployed under the Plan, such as 

improved situational awareness and agent safety. 

While CBP has defined these mission benefits, the agency has not 

developed key attributes for performance metrics for all surveillance 

technologies to be deployed as part of the Plan, as we recommended in 

November 2011.

13 In our April 2013 update on the progress made by the 

agencies to address our findings on duplication and cost savings across 

the federal government, CBP officials stated that operations of its two 

SBInet surveillance systems identified examples of key attributes for 

metrics that can be useful in assessing the Plan’s implementation for 

technologies.14

 

13

For example, according to CBP officials, to help measure 

whether illegal activity has decreased, examples of key attributes include 

decreases in the amount of arrests, complaints by ranchers and other 

citizens, and destruction of public and private lands and property. While 

the development of key attributes for metrics for the two SBInet

surveillance systems is a positive step, CBP has not identified attributes 

for metrics for all technologies to be acquired and deployed as part of the 

GAO-12-22. 

14GAO, 2013 Annual Report: Actions Needed to Reduce Fragmentation, Overlap, and 

Duplication and Achieve Other Financial Benefits, GAO-13-279SP, (Washington, D.C.: 

Apr. 9, 2013). 

CBP Has Identified 

Mission Benefits, but 

Does Not Capture 

Complete Data on the 

Contributions of Its 

Surveillance 

Technologies
 

Page 10 GAO-14-411T 

Plan. Thus, to fully address the intent of our recommendation, CBP would 

need to develop and apply key attributes for performance metrics for each 

of the technologies to be deployed under the Plan to assess its progress 

in implementing the Plan and determine when mission benefits have been 

fully realized.

Furthermore, we reported in March 2014 that CBP is not capturing 

complete asset assist data on the contributions of its surveillance 

technologies to apprehensions and seizures, and these data are not 

being consistently recorded by Border Patrol agents and across locations. 

Although CBP has a field within its Enforcement Integrated Database 

(EID) for maintaining data on whether technological assets, such as 

SBInet surveillance towers, and non-technological assets, such as canine 

teams, assisted or contributed to the apprehension of illegal entrants, and 

seizure of drugs and other contraband, according to CBP officials, Border 

Patrol agents are not required to record these data.15

We reported that according to our analysis of EID asset assist data for 

apprehensions and seizures in the Tucson and Yuma sectors from fiscal 

year 2010 through June 2013, information on asset assists was generally 

not recorded for all apprehension and seizure events.

This limits CBP’s 

ability to collect, track, and analyze available data on asset assists to help 

monitor the contribution of surveillance technologies, including its SBInet

system, to Border Patrol apprehensions and seizures and inform resource 

allocation decisions.

16

 

15 In addition to maintaining data on asset assists, the Border Patrol collects and 

maintains data on apprehensions and seizures in DHS’s EID.

For instance, for 

the 166,976 apprehension events reported by the Border Patrol across 

the Tucson sector during fiscal year 2010 through June 2013, an asset 

assist was not recorded for 115,517 (or about 69 percent) of these 

apprehension events. In the Yuma sector, of the 8,237 apprehension 

events reported by Border Patrol agents during the specified time period, 

an asset assist was not recorded for 7,150 (or about 87 percent) of these 

16 In our March 2014 report, we defined an “apprehension or seizure event” as the 

occasion on which Border Patrol agents make an apprehension of an illegal entrant or a 

seizure of drugs or other contraband. The event is recorded in the EID and a date and 

unique identifying number are assigned. An event can involve the apprehension of one or 

multiple illegal entrants or types of items, and each individual illegal entrant apprehended 

or type of item seized in the event is associated with the assigned unique identifying 

number. Our analysis of apprehension events included instances in which an event had at 

least one deportable individual.
 

Page 11 GAO-14-411T 

apprehension events. Since data on asset assists are not required to be 

reported, it is unclear whether the data were not reported because an 

asset was not a contributing factor in the apprehension or seizure or 

whether an asset was a contributing factor but was not recorded by 

agents. 

As a result, CBP is not positioned to determine the contribution of 

surveillance technologies in the apprehension of illegal entrants and 

seizure of drugs and other contraband during the specified time frame. 

We reported that an Associate Chief at Border Patrol told us that while 

data on asset assists are not systematically recorded and tracked, Border 

Patrol recognizes the benefits of assessments of asset assists data, 

including those from surveillance technologies, such as the SBInet

system. The Associate Chief further noted that these data in combination 

with other data, such as numbers of apprehensions and seizures, are 

used on a limited basis to help the agency make adjustments to its 

acquisition plans prior to deploying resources, thereby enabling the 

agency to make more informed deployment decisions. 

We recommended that CBP require data on asset assists to be recorded 

and tracked within EID and that once these data are required to recorded 

and tracked, analyze available data on apprehensions and technological 

assists, in combination with other relevant performance metrics or 

indicators, as appropriate, to determine the contribution of surveillance 

technologies to CBP’s border security efforts. CBP concurred with our 

recommendations and stated that Border Patrol is changing its data 

collection process to allow for improved reporting on asset assists for 

apprehensions and seizures and intends to make it mandatory to record 

whether an asset assisted in an apprehension or seizure. DHS plans to 

change its process by December 31, 2014.

Chairwoman Miller, Ranking Member Jackson Lee, and members of the 

subcommittee, this concludes my prepared statement. I would be pleased 

to answer any questions that you may have.
 

Page 12 GAO-14-411T 

For questions about this statement, please contact Rebecca Gambler at 

(202) 512-6912 or gamblerr@gao.gov. Contact points for our Offices of 

Congressional Relations and Public Affairs may be found on the last page 

of this statement. Individuals making key contributions to this testimony

and our related report are Jeanette Espinola, Assistant Director, and 

Michelle Woods, Analyst-in-Charge. Additional contributors include David 

Alexander, Frances Cook, Joseph E. Dewechter, Jennifer Echard, Yvette 

Gutierrez, Richard Hung, Jason Lee, Grant Mallie, Karen Richey, Doug 

Sloane, Nate Tranquilli, Katherine Trimble, and Jim Ungvarsky.

GAO Contact and 

Staff 

Acknowledgments

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